PRIVACY AND PERSONAL INFORMATION
The intent of this policy is to follow the Personal Information Protection and Electronic Documents Act (PIPEDA) and to inform students, employees and any other person(s) for whom information is required, of their right to privacy when submitting information to IGNITE or for information IGNITE gather from other sources (i.e. Humber ITAL, University of Guelph-Humber) for the purpose of providing student services.
IGNITE is committed to being accountable and responsible for all employee and student information collected and the processes used in its collection. IGNITE ensures compliance with all applicable Canadian legislation. The Chief Executive Officer is responsible for the duties for fulfilling requirements and maintaining accountability within the organization. All personal information will be stored in accordance with Ontario privacy legislation, and will be:
- Collected with consent and for reasonable purpose
- Used and disclosed for the limited purpose for which it was collected
- Accessible for inspection and correction by authorized personnel only
- Stored securely
IGNITE may ask students and staff for demographic and group identity data in relation to reviewing, improving and updating programs, services and organizational systems, with the goal of greater equity and effectiveness. IGNITE only collects information required for its services and activities.
IGNITE collects employee information for the following purposes:
- For recruiting and contracting purposes;
- To administer payroll, benefits, and retirement plans;
- To process any benefit or other claims such as WSIB or medical related claims;
- To manage our employment relationship, including any performance evaluations, compensation, or disciplinary measures;
- To establish training or development requirements;
- To comply with applicable employment and human rights legislation; and,
- To send work related letters, communications, materials, and packages as necessary.
All information that is needed and not currently in the possession of IGNITE will be collected only as required. In instances where IGNITE collects previously unattained student or employee information, notification will be provided at the bottom of any information form setting out the purpose for which the information is being collected, used, and/or disclosed. By completing the form, a student or employee agrees to the collection, use, and/or disclosure of the information for the purpose identified.
Any information is issued to IGNITE by Humber ITAL or the University of Guelph-Humber has already been accepted and consented to when tuition and student fees have been paid.
IGNITE will not collect more information than required to perform the service(s) at hand and any information collected or distributed to IGNITE by the Institution will not leave the possession of IGNITE unless it is specifically needed by the outsourced service provider. IGNITE ensures that any third-party agent to whom information is transferred engages in appropriate security measures to protect personal information.
LIMITING USE, DISCLOSURE AND RETENTION
IGNITE will not use any information which has been personally collected or distributed to IGNITE by the Institution for any purpose other than that which was originally identified. IGNITE will not sell any information to any third party.
When IGNITE no longer requires personal information either for the purpose identified or in order to comply with legal retention laws, the use will be ceased, and documents physically and/or digitally destroyed.
EXCEPTIONS TO CONFIDENTIALITY
IGNITE may collect, use, and disclose an employee’s employment-related personal information without consent if it is reasonable for the purposes of establishing, managing, or terminating the employment relationship. If consent is required, we will explain why the information is being collected and how we intend to use it.
We may collect personal information without your knowledge or consent if:
- It is clearly in your interests and consent is not available in a timely manner;
- Knowledge and consent would compromise the availability or accuracy of the information and collection is required to investigate a breach of an agreement with IGNITE, inclusive of policies of which you have been made aware, including those of the Institution, or contravention of a federal or provincial law; and,
- It is publicly available.
We may use personal information without your knowledge or consent if:
- We have reasonable grounds to believe the information could be useful when investigating a contravention of federal or provincial law, and the information is used for that investigation;
- An emergency threatens an individual’s life, health, or security;
- It is publicly available;
- The use is clearly in your interest and consent is not reasonably available in a timely manner; and,
- Knowledge and consent would compromise the availability or accuracy of the information and collection are required to investigate a breach of an agreement with IGNITE, inclusive of policies of which you have been made aware, including those of the Institution, or contravention of federal or provincial law.
We may disclose personal information without your knowledge or consent only to:
- Counsel representing IGNITE;
- Collect a debt owed to IGNITE;
- Comply with a subpoena, warrant or an order made by a court or judicial or administrative body with appropriate jurisdiction;
- A government institution that has requested the information identified its lawful authority, and indicated that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal or provincial law; or suspects that the information relates to national security or the conduct of international affairs, or is for the purpose of administering any federal or provincial law;
- An investigative body named in the applicable legislation or regulations of a government institution on our initiative when we believe the information concerns a breach of an agreement with IGNITE, inclusive of policies of which you have been made aware, including those of the Institution, or contravention of federal or provincial law or reasonably suspect the information relates to national security or the conduct of international affairs;
- Made by an investigative body for the purposes related to the investigation of a breach of an agreement or a contravention of a federal or provincial law; and,
- An emergency threatening your life, health, or security, where we will inform you of the disclosure.
All information IGNITE gathers for the purposes of employment and providing services to students will be kept in a secure physical or digital location. Those who do not require access to any information within IGNITE will not be granted access.
If information IGNITE has in its possession requires a level of security not already implemented within IGNITE, IGNITE will invest in an appropriate security measure to protect such information.
ACCURACY OF PERSONAL INFORMATION
IGNITE will make every effort to ensure the employee personal information it holds is accurate, remains current and is updated internally, and with third-party suppliers in a timely manner. Employees are expected to update IGNITE of any changes to their personal information. An employee may submit a written request to the Chief Executive Officer to correct any errors or omissions in any of their personal information maintained by IGNITE.
By law, all employees and students of Humber ITAL and University of Guelph-Humber have the right to request their information be shown to them. No student or employee will ever be denied access to their personal information held within IGNITE and will receive a response no later than ten (10) business days after having received the request. Should IGNITE not be able to comply with the request within this timeframe, a reason and an anticipated timeline for delivery, unless prohibited by law, will be provided.
All individuals who provide information to IGNITE have the right to challenge the compliance of IGNITE with regard to privacy and policy issues. If there are any issues with the way IGNITE is dealing with privacy, an individual has the right to challenge the inaccuracy. The employee or Member challenging the compliance of IGNITE must make an appointment with the Chief Executive Officer to discuss the matter in a preliminary meeting. Together the group will communicate some form of resolution and make appropriate changes to the way in which IGNITE deals with privacy issues, should such be warranted.
Date adopted: October 2, 2013
Date reviewed: November 12, 2014
Date reviewed: November 18, 2015
Date reviewed: October 17, 2017
Date reviewed: March 30, 2021
Date revised: February 10, 2022